0 évaluation0% ont trouvé ce document utile (0 vote)
25K vues18 pages
A Chicago school teacher has been charged with dealing ammunition and gun accessories, federal authorities announced Wednesday.
The teacher was identified as Brent Turpin who, the U.S. Attorney's office said is a South Side teacher.
A Chicago school teacher has been charged with dealing ammunition and gun accessories, federal authorities announced Wednesday.
The teacher was identified as Brent Turpin who, the U.S. Attorney's office said is a South Side teacher.
A Chicago school teacher has been charged with dealing ammunition and gun accessories, federal authorities announced Wednesday.
The teacher was identified as Brent Turpin who, the U.S. Attorney's office said is a South Side teacher.
RECEIVED
AO 91 (Rev. 11/11) Criminal Complaint AUSA Ankur Srivastaya (323 358-9148
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS. MaeRaaen
EASTERN DIVISION MAGISTRATE JUDGE
[UNITED BTATES DISTRIGT GOURT
UNITED STATES OF AMERICA
CASE NUMBER:
v.
UNDER SEAL
“es 7CR 568
,
CRIMINAL compan: -
MAGISTRATE JUDGE WEISMAN
I, the complainant in this ease, state that the following is true to the best of my knowledge and belief.
Count One
From on or about June 18, 2017 to on or about August 2, 2017, at Chicago, in the Northern District of
Illinois, Eastern Division, and elsewhere, the defendant violated:
Code Section Offense Description
Title 18, United States Code, Sections Defendant conspired with Juvenile A to dispose of a
871 and 922(4)(1) firearm and ammunition to CI, while knowing or
having reasonable cause to believe that CI had been
previously convicted of a felony
it Two
On or about August 2, 2017, at Chicago, in the Northern District of Illinois, Eastern Division, and
elsewhere, the defendant violated:
Code Section Offense Description
Title 18, United States Code, Section Defendant disposed of ammunition to CI, while
922(€)(1) Knowing or having reasonable cause to believe that CI
had been previously convicted of a felony
‘This criminal complaint is based upon these facts:
-X_ Continued on the attached sheet.
‘THOMAS CALLAGHAN
Special Agent, Federal Bureau of Investigation
‘Sworn to before me and signed in my presence. * .
Date: August 28, 2017
Judge's signature
City and state: Chicago, is E
Printed name and Title
AUG 28 2017
THOMAS G, BRUTON.
CLERK, U.S. DISTRICT COURTUNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS |»
IDAVIE
I, THOMAS CALLAGHAN, being duly sworn, state as follows:
1. Tama Special Agent with the Federal Bureau of Investigation, and have
been so employed since approximately July 2010. As part of my duties as an FBI
Special Agent, I investigate criminal violations relating to violent crimes, including,
among others, kidnapping, homicides, and the apprehension of violent fugitives.
2, This affidavit is submitted in support of a criminal complaint alleging
that BRENT TURPIN has violated Title 18, United States Code, Sections 371 and
922(d)(1). I have not included each and every fact known to me concerning this
investigation, because this affidavit is being submitted for the limited purpose of
establishing probable cause in support of a criminal complaint charging TURPIN
with: 1) conspiracy to dispose of any firearm or ammunition to a felon, while knowing
or having reasonable cause to believe that such person is a felon, and 2) disposing of
ammunition toa felon, while knowing or having reasonable cause to believe that such
person is a felon. I have set forth only the facts that I believe are necessary to
establish probable cause to believe that the defendant committed the offenses alleged
in the complaint.
3. This affidavit is based on my personal knowledge, on information
provided to me by other law enforcement agents, and on information provided by
other persons with knowledge regarding relevant facts.4, In summary, this affidavit describes how, over the course of several
weeks, TURPIN conspired with Juvenile A to provide firearms and ammunition to a
confidential informant working with the FBI (“CI’). On August 2, 2017, TURPIN did
in fact provide CL with two boxes containing three types of ammunition. In particular,
this affidavit describes the following events: 1) Conversations involving TURPIN,
Juvenile A, and Cl in which Juvenile A and TURPIN agree to assist CI in obtaining
a firearm; 2) a June 24, 2017 trip to a gun show in Indiana at which TURPIN and CI
attempted to purchase two Glock firearms for CI’s use; 8) an August 1, 2017 meeting
at which TURPIN provided CI with an extended handgun magazine and a laser sight
which is designed to attach to the front of a handgun; and 4) an August 2, 2017
meeting at which TURPIN provided CI with two boxes of ammunition. Because, as
farther described below, TURPIN knows or has reasonable cause to believe that CL
is a felon, TURPIN’s agreement with Juvenile A to provide firearms and ammunition
to CI constitutes a violation of Title 18, United States Code, Sections 871 and
922(@)(1).
I BACKGROUND INFORMATION
5. TURPINis currently employed as a special education teacher at a public
elementary school, which is located in the Englewood neighborhood of Chicago and is
part of the Chicago Public Schools system.
6. Juvenile A lived with TURPIN prior to his incarceration, and TURPIN
is believed to be Juvenile A’s guardian.7. As part of its investigation, the FBI has obtained information that
TURPIN is supplying firearms and amnwunition to felons as well as to juveniles. In
order to further investigate these allegations, the FBI enlisted the assistance of the
confidential informant referred to in this affidavit as “CI”. Clis personally close with
Juvenile A, and, as a result of CI’s relationship with Juvenile A, CI and TURPIN are
also familiar with one another.
Il. JUNE 18, 2017: JUVENILE A TELLS CI THAT HE WILL ASK
‘TURPIN TO HELP CI OBTAIN A FIREARM
8. On June 18, 2017, while incarcerated at a juvenile detention facility,
Juvenile A participated in a phone call with TURPIN, at which time TURPIN, at
Juyenile A’s direction, dialed CI's phone number to initiate a three-way
conversation.? During the conversation, TURPIN walked away from the phone while
Juvenile A and CI continued to speak with one another, stating: “I'm gonna mute you
on my end. I gotta go do some stuff, so you all talk.” As further described below, CI
then told Juvenile A that he and other gang members needed firearms to protect
1 CT has prior convictions for firearms related offenses, and, as a result of cooperating with
state law enforcement officials, CI received a reduced sentence on one of his cases. Since that
time, the FBI has paid Cl approximately $ 8,170 to compensate CI for his assistance in this
investigation. At his initial meeting with FBI, CI was briefed on many topics, and provided
inaccurate information regarding a shooting that is unrelated to the events described in this,
affidavit; CI later corrected his statement and has since provided what the FBI deems to be
truthful information, which in many instances has been independently corroborated. The
events described in this affidavit have been corroborated by surveillance and/or recordings.
2 Agents identified TURPIN as a participant in the phone call because records from the
juvenile detention facility identify the phone number in contact with Juvenile A; this is the
same phone number that CI has used to contact TURPIN throughout the investigation.themselves, and, in tun, Juvenile A told CI that he would instruct TURPIN to give
Cla firearm. Portions of the conversation are transcribed below.
9. Prior to stating that he would help CI obtain a firearm, Juvenile A
explained that he was reluctant to provide firearms to other individuals in the gang
because he had already done so, which resulted in the guns being lost or thrown
away:t
Juvenile A: I kept trying to send something [a firearm] his way
but that shit ain't looking good. It ain't looking
good... They just did what they did shorty and them
just lost two..
ck Oh, you said you already situated [provided a
firearm to] a motherfucker already?
Juvenile A: Yeah boy, they lost that bitch [firearm]. Boy that
shit. This shit over with. I can’t keep doing this shit.
‘Them five hundred dollars a stain [the firearms cost
Juvenile A $500 each]. I can’t keep losing thousands
of dollars and motherfuckers being throwing.
Based on my training and experience, and based on the context of the surrounding
conversation, I bélieve that, during this portion of the conversation, Juvenile A was
® The juvenile facility at which JUVENILE A was being housed informs inmates and
individuals in contact with them that their calls are recorded and monitored by playing the
following recorded message: “This cal] is subject to recording and monitoring.”
4 The language quoted from the recorded conversations throughout this affidavit are based
on a preliminary review of the recorded conversations, and not on final transcripts. The
summaries of the recorded conversations do not include all statements or topics covered
during the course of the recorded conversations. At various points in the affidavit, I have
included in brackets my interpretation of words and phrases used in the recorded
conversations. I base my interpretations on information received from cooperating sources,
the content and context of the recorded conversations, events occurring before and after the
conversations, my knowledge of the investigation as a whole, my experience and training,
and the experience and training of other law enforcement agents involved in this
investigation,explaining to CI why he was reluctant to part with his firearms. Specifically, Juvenile
A explained that, in the past, giving firearms to other members of the gang had
resulted in the firearms being lost, which caused a monetary loss to Juvenile A.
10. Later in the conversation, CI reassured Juvenile A by saying that he
would be willing to give TURPIN, who was holding Juvenile A’s firearms, a $300
deposit; if the firearm was lost, CI would then give TURPIN another $200 so that
Juvenile A would be compensated with $500 to replace the lost firearm:
Cl:
Juvenile A:
ck
Cl:
Juvenile A:
cl:
Juvenile A:
Til take responsibility for it. You feel me?... If push
comes to shove and anything happen, you feel me?
So to make sure that things are good I'l give dude
ITURPIN] like three hundred ... and then if
anything happens, Tl give him the other two. To
replace that [firearm].
T’m fina send something their way pronto.
...look, I'm gonna be responsible for it [the firearm].
So look, if you gonna do that, you holler at dude
(TURPIN]... and Pl make it happen. I'll give dude
the money.
... if we gonna do it send it through me...
Alright.
T'm gonna give dude TURPIN] the bread [money]...
Alright, white folk [TURPIN] gonna come see me
tomorrow and I’m gonna tell him what to do.
Based on my training and experience, and based on the context of the surrounding
conversation, I believe that, during this portion of the conversation, CI reassured
Juvenile A by promising to give TURPIN a $300 deposit, as well as an additional $200
toreplace Juvenile A’s firearm if another gang member lostit. CI then asked JuvenileA to “send it through me,” which meant that CI would take possession of a firearm
from TURPIN, which Cl would then redistribute to other gang members. Juvenile A
agreed to this plan, and informed CI that he would talk to TURPIN the next day and
tell him to provide CI with one of his firearms.
Il. JUNE 20, 2017: TURPIN AGREES TO HELP CI OBTAIN A
FIREARM
11. On June 20, 2017, CI met with TURPIN at TURPIN’s residence on the
south side of Chicago. FBI agents as well as Chicago Police officers conducted
surveillance, and CI was provided with video and audio recording equipment which
captured the meeting. During the meeting, as further described below, TURPIN
offered to assist CT in obtaining a firearm.
12, First, TURPIN discussed the burglary of a gun store, which Juvenile A
is believed to have been involved in. TURPIN elaborated that, unbeknownst to
Juvenile A, TURPIN had provided two of Juvenile A's firearms to some investigators
who were looking into the burglary:
TURPIN: Come in. We gotta chat. Um, cause he [Juvenile A]
don’t even know what's going on... [haven't told him,
cause I don’t want him to worry. But you know all
the mess that’s going on with Romeo.
ck With Romeo. Yeah they saw they charged him with
the gun store.5
‘TURPIN: Yeah, so um, right after that happened investigators
came here and I’ve got two guns. One of them
registered and one not. They asked for them. And I
5 During this portion of the conversation, TURPIN and CI appeared to be referencing a
pending federal case involving a defendant by the name of Romeo Blackman, who is currently
charged with participating in the burglary of a gun store in case number 17 CR 871.did volunteer them cause... well they didn't come
from there [the gun store which was burglarized) ....
There's nothing they're gonna find on them. But
right now that’s where they are. [Juvenile A] does
not know that.6
13. Later in the conversation, TURPIN sympathized with C's predicament
in not having a firearm:
‘TURPIN: He got some money if you need some money [to
obtain a firearm]. Cause that’s what I thought you
was wanting... mean, I know you guys out there. I
know you guys are.
ck ‘Yeah. My brother got killed like two weeks ago.
TURPIN: I don't like being out here without a gun either cause
too many people know where he (Juvenile Al, know
he live here.”
Based on my training and experience, and based on the context of the surrounding
conversation, I believe that, during this portion of the conversation, TURPIN
acknowledged that CI was looking for TURPIN’s assistance in obtaining a firearm.
14, TURPIN then explained that while he no longer possessed Juvenile A’s
firearms, he did possess some accessories that went with them: “... that one T still
have his paraphernalia but I don’t have the actual gun... I said I got his
paraphernalia, like his bullets and clip and stuff but I don’t have the actual gun.”
15. TURPIN also offered to obtain a firearm from Oklahoma, where
‘TURPIN was apparently planning to travel: “’'m going to go back to Oklahoma here
in a couple weeks, um, I'll see what's going on out there.”
6 Agents are not aware of any investigators who actually took possession of the two firearms
mentioned by TURPIN.16. CI reiterated that his brother had recently been killed, and then
explained to TURPIN: “It’s cracking out here. It’s kind of hard for a motherfucker to
come across something, you know, cause we into it with every motherfucker. Every
motherfucker, you know, motherfucker don’t want us, don’t want us with none, you
know?” Based on my training and experience, and based on the context of the
surrounding conversation, I believe that, during this portion of the conversation, CI
was explaining to TURPIN his difficulties in obtaining a firearm [“It’s kind of hard...
to come across [a gun]”.
17. TURPIN then asked Cl if CI had any connections he could use to
purchase a gun, and then agreed to drive CI to Michigan so that they could buy
firearms:
TURPIN:
CI:
CI:
TURPIN:
Where are you looking? Are you looking... do you
know anybody on the west side or anything like
that?
Iknow some people:.. we just got to take a little ride
‘though... that’s the only thing. See and I ain’t got
no license 60...
Where do you gotta go?
Um, like Michigan... it’s probably like two hours,
two hours away or something like that.”
Let me ponder that. I gotta couple days to get stuff
wrapped up at work and then I'll have free time.
That's a possibility, I mean I, that's a possibility. I
could take you somewhere... Call me on Friday and
welll figure it out.TURPIN: See if that will work, let’s talk on Friday. I don’t
want nobody going.
CL: No, just you and me.
‘TURPIN: If we go, itll just be two of us... Yeah we can
definitely do it.
IV. JUNE 23, 2017: PREPARING FOR THE GUN SHOW
18. On June 23, 2017, CT went to TURPIN’s house in Chicago and the two
of them discussed a trip to a gun show in Indiana. FBI agents conducted surveillance,
and CI was provided with video and audio recording equipment which captured the
meeting.
19. During the meeting, TURPIN expressed his concerns about filling out
any paperwork in connection with a gun purchase, presumably because he did not
want any firearms which could later be used in a crime traced back to him. He told
CL, “In some states you can just buy directly from somebody and there's no paper trail
at all. I don’t know about Indiana.” He also informed CI, “I don’t want to get nothing
T'm going to have to fill out papers for. That's the only thing.”
20. — Inspite of his concerns, TURPIN predicted that they may be successful
finding a seller who would not require them to fill out any paperwork: “Are there
gonna be guys there that are... selling something without paperwork? That’s what
you want to know. And there very well may be...” ‘TURPIN further commented, “Just
because the rules say it has to be done this way, doesn’t mean there won't be people...
walking around trying to sell something.”21, Finally, TURPIN gave CI advice to “Dress well... look sharp, don’t look
suspicious.”
V. JUNE 24, 2017: THE TRIP TO THE GUN SHOW
22. On June 24, 2017, TURPIN drove CI from Chicago to an Indiana gun
show in order to purchase firearms. FBI agents conducted surveillance, and CI was
provided with video and audio recording equipment which captured the meeting.”
During the day's events, as further described below, TURPIN offered to assist CI in
obtaining a firearm, which TURPIN knew CI would not be able to purchase himself
based on his criminal background. Prior to entering the gun show, CI stated,
probation and shit when I had caught the gun case and shit....”8
283. On the drive to the gun show, TURPIN instructed CI what to do and say
when they arrived at the gun show: “If they ask you if you're from Indiana say yes, if
they say where you from, say like, say South Bend, or something or Indianapolis.
‘There will be um just'so you know, theré will be law enforcement there... they don’t
check nothing, they're just there so I just wanted to let you know.”
1 While the audio recording equipment properly functioned during the duration of the gun
show visit, the battery of the video recording equipment ran out as Cl and ‘TURPIN arrived
at the gun show. However, agents were present at the gun show and personally observed the
events described in Section V of this affidavit.
§ In addition, on August 2, 2017, during a recorded conversation, CI and TURPIN talked
about the potential penalties Juvenile A faced in his pending case, During this conversation,
‘TURPIN acknowledged that CI had spent time in the Cook County Department of
Corrections: “I mean he's scared bout going to the County, bout going to prison, he don’t
wanna go, I can’t blame him... But I don't know, you've been through that County thing [Cook
County Department of Correctionsl, I don't know what itd be like for him.”
1024, Later on in the car ride, TURPIN further advised CI what to do at the
gun show: “Now when you get out here, look around. Small tables. You see people
that you know have big signs, they're not who you want.”
25. CI and TURPIN then arrived at the gun show, and eventually
approached one of the firearms dealers. The firearms dealer asked TURPIN, “Who's:
buying them?” TURPIN replied “Both of us.” The dealer then asked TURPIN and Cl,
“You guys are from Indiana?” TURPIN and CI both replied, “Yeah.”
26. CI picked out two Glock firearms which were collectively priced at $590.
‘TURPIN removed cash from his pocket and gave the firearms dealer $600 for the two
Glock handguns which CI had selected. As the transaction was being completed, the
firearms dealer told TURPIN, “I’m going to need you to show me your driver’s
license.” TURPIN refused to provide identification, and retrieved the $600 which he
had already handed to the firearms dealer.
27. ‘TURPIN and CI walked out of the gun show, at which time CI asked
‘TURPIN if he would try to talk to the dealer again. TURPIN responded, “I don’t think
you'll win but you can try. Oh, because it looks suspicious having a white man and a
black boy there. I thought we had it cool. The problem is he can sit there and tell
everybody not to sell nothing and he’s the only one that I picked out that it was
obvious he wasn’t a dealer.”
28. TURPIN and CI continued to talk about whether they should make
another attempt to purchase the firearms when TURPIN told CI, “The problem is we
made. Buddy, I think we gotta do a different plan.” When CI asked TURPIN what
uwthat plan was, TURPIN stated, “I don’t know. Find another one. Um, find another
show that’s coming up. They'll be another one coming up. Pick up something when I
go back to Oklahoma. See if those guys in Michigan come through. I wouldn't go back
in there. I know you want that but the last thing you want to do is have him hand
that gun over to you and have him nodding at some deputy sitting there to pick you
up and they sure as hell might do something like that. They sure as hell might do
something like that.”
29. TURPIN and CI then returned to Chicago without having successfully
purchased any firearms at the June 24, 2017 gun show. Shortly after the gun show,
TURPIN traveled to Oklahoma for a portion of the summer.
VI. JULY 2017: TURPIN AND JUVENILE A CONTINUE TO TELL CI
‘THAT THEY WILL ASSIST HIM IN OBTAINING A FIREARM
30. On July 6, 2017, while incarcerated at a juvenile detention facility,
Juyenile A participated in a phone call with an unidentified individual, who, at
Juvenile A’s direction, dialed CI’s phone number to initiate a three-way conversation.
During their conversation, Juvenile A asked CI whether TURPIN had given CI any
of Juvenile A’s firearms:
JUVENILE A: Iknow I got some shit [firearms] at the crib. He ain't
give you that shit I got at the crib?
ck: Man he ain’t give me shit.
31, On July 11, 2017, while TURPIN was in Oklahoma, TURPIN agreed to
look for a firearm which he could bring back to Chicago and provide to Cl:
cl: Alright, look around for me.
12TURPIN: Alright, I am.
ck Ifyou see something [a firearm] let me know... cause
Ineed something real bad.
‘TURPIN: Alright, alright.
VI. AUGUST 1, 2017: TURPIN GIVES A HIGH CAPACITY
MAGAZINE AND A LASER SIGHT TO CI
32. On August 1, 2017, TURPIN and CI went to court together and attended
Jayenile A’s court appearance.
33. After court, CI went to TURPIN’s residence, at which time TURPIN
provided CI with an extended capacity firearm magazine as well as a firearm laser
sight. FBI agents conducted surveillance, and CI was provided with video and audio
recording equipment which captured the meeting.
34. When Cl arrived at TURPIN’s residence, they had a conversation during
which CI stated, “You said we could check out the um the shit the clip or whatever.”
35. TURPIN asked CI to wait upstairs while he went to the basement of his
residence. When TURPIN emerged from the basement, he gave CI an extended
magazine clip (with no ammunition) as well as a laser sight. TURPIN explained,
“Phis what he [Juvenile A] still has. I think I got a box of, uh, 9 [mm] shells, I don’t
think that’s a 9 [mm magazine] though. The shells are gone.” He later said, “I thought
Thad a box of shells, I swear I had a box of shells. Do you want that stuff?”
36. Later in the conversation, TURPIN told CI that the laser sight “will go
on about anything I think and if that one won't work, trade it for something.”
1337. CT placed the extended high capacity handgun magazine and tactical
handgun laser provided by TURPIN in a towel, which he then placed inside a bag. CI
left TURPIN’s residence with the bag containing the magazine and laser, and met
with agents shortly thereafter, at which time agents recovered the high capacity
magazine and laser sight.
VIII. AUGUST 2, 2017: TURPIN GIVES AMMUNITION TO CL
38. On August 2, 2017, CI went to TURPIN’s residence, at which time
TURPIN provided CI with several types of ammunition. FBI agents and Chicago
Police Officers conducted surveillance, and CI was provided with audio recording
equipment which captured the meeting. As further described below, TURPIN
provided CI with two boxes containing three different types of ammunition.
39. When Cl arrived at TURPIN’s residence, he stated that he needed some
ammunition: “So the only thing is, I need some shit, I need some shells
[ammunition].”. TURPIN replied, “What kind of shells do you got, I mean that’s
easy... What kind of shells do you want?” CI responded, “I'm cause um, like some 9's
and uh .45 cause um cause they are shooting and shit around my 0.G. crib yesterday
and I don’t want like when I pulled up and shit, they were shooting around there
so...” TURPIN clarified, “Some 9's and .45’s?”
® CI was also provided with video recording equipment, but that equipment malfunctioned
and did not record any of the events described.
1440. ‘TURPIN then went to his basement and retrieved two clear boxes
containing ammunition, which he then gave to Cl. The boxes contained eight 9mm.
rounds, two .40 caliber rounds, and twenty .45 caliber rounds.
41. TURPIN and CI then had a conversation in which TURPIN stated that
Juvenile A may have hidden a 9 mm firearm in his home, but that TURPIN had been
unable to locate it:
TURPIN: Alright, I think you got everything in the house.
cl: [Laughing].
TURPIN: I still think there's something, [Nickname for
Juvenile A] thinks there's one hid over here. But I've
looked everywhere he told me to look and couldn't
find it.
cr: You said a gun?
TURPIN: He said he thought that. I mean it’s bad when you
don’t even know. He said he thought that he had
foothee 9 [mm firearm] here but I really can’t find
42. At the end of the conversation, TURPIN instructed Cl, “Wipe those
[bullets] down before you put them in anything... [Juvenile A] touched them.” Based
on my training and experience, I understand that when TURPIN instructed CI to
wipe down the ammunition, he did so because he was concerned that Juvenile A’s
fingerprints may be on the ammunition and he did not want the bullets traced back
to himself or to Juvenile A if the bullets were used in a subsequent crime.
43. CI left TURPIN’s residence with a bag containing the two boxes of
ammunition, and met with agents shortly thereafter. A photograph of the two boxes
15of ammunition which TURPIN gave to CI and which were later recovered by FBI
agents is below:
S 2
sao '
sill 2P
re
CONCLUSION
44. Based upon the foregoing facts, I respectfully submit that there is
probable cause to believe that: 1) from on or about June 18, 2017, and continuing
through on or about August 2, 2017, defendant BRENT TURPIN did commit the
offense of conspiracy to dispose of any firearm or ammunition to a felon, while
knowing or having reasonable cause to believe that such person is a felon, in violation
of Title 18, United States Code, Sections 371 and 922(4)(1); and 2) on or about August
2, 2017, defendant BRENT TURPIN did dispose of ammunition to a felon, while
16knowing or having reasonable cause to believe that such person is a felon, in violation
of Title 18, United States Code, Section 922(d)(1).
FURTHER AFFIANT SAYETH NOT.
THOMAS CALLAGHAN
Special Agent
Federal Bureau of Investigation
SUBSCRIBED-AND SWORN to before me on August 28, 2017.
M. DAVID WEISMAN
United States Magistrate Judge
17